TIMBER PRODUCTS April 2024 HT Newsletter Volume: 04/24/2024

IPPC Marking of Processed Wood Material

When looking at the current regulations for ISPM 15 on page 15-6, Section 2.1 Exemptions states:

The following articles are of sufficiently low risk to be exempted from the provisions of this standard:

• wood packaging material made entirely from thin wood (6 mm or less in thickness)
• wood packaging made wholly of processed wood material, such as plywood, particle board, oriented strand board or veneer that has been created using glue, heat or pressure, or a combination thereof
• barrels for wine and spirit that have been heated during manufacture gift boxes for wine, cigars and other commodities made from wood that has been processed and/or manufactured in a way that renders it free of pests
• sawdust, wood shavings and wood wool
• wood components permanently attached to freight vehicles and containers.

In Annex 2, page 15-17 of ISPM 15, it states the following when marking wood packaging material:

Where various components are integrated into a unit of wood packaging material, the resultant composite unit should be considered as a single unit for marking purposes. On a composite unit of wood packaging material made of both treated wood and processed wood material (where the processed component does not require treatment) , it may be appropriate for the mark to appear on the processed wood material components to ensure that the mark is in a visible location and is of a sufficient size.

In other words, the application of the mark on processed wood material is acceptable on multi-component wood packaging where such application is done to ensure the mark is seen.  Facilities should also place a mark on the actual wood WPM product to verify conformance but if the processed wood material is what will be seen by Customs in a container, then also applying the mark on the this material is appropriate and allowed by ISPM 15. 

Please contact your inspector or the TP Director of Wood Packaging with any questions related to processed wood material or any of the other items listed in ISPM 15's "Exemptions" section.

Mark Retrieval Protocol

The American Lumber Standard Committee, Inc. (ALSC) Wood Packaging Material Enforcement Regulations from November 7, 2014 state in Section 5.6.12:

"An accredited agency shall have an ongoing practice of reporting and reviewing stamp inventories, generally monthly, to ensure reconciliation in agency records regarding the types and number of stamps issued to each facility."

The marks issued to a facility related to the IPPC/HT program are highly regulated by the U.S. Government.  These marks come in various forms:

• Stamps
• Brands
• Stencils
• Inkjet systems
• Lasers

Regardless of the types possessed, TP is required by ALSC regulations to maintain an inventory of all IPPC and HT related marks to verify there is no change in mark numbers that is unaccounted for.  Marks that are damaged or too worn to continue using should be held for retrieval by the TP Inspector.  They should not be disposed of or destroyed by the facility since TP must reconcile the inventory each month.  Once unusable marks are retrieved, the TP Inspector will update the inventory on his report and the mark will be properly disposed of.

The security of all marks is critical and lost or missing marks create a non-conformance for the facility.  Ongoing issues with the security of marks can lead to very serious consequences, so facilities need to make certain all marks are kept up with and properly secured when not in use.